WHISTLEBLOWING POLICY

Copyright: Selangor Dredging Berhad

All rights reserved.
None of the information contained in this document shall be disclosed outside
the recipient’s own company and no part of this document may be reproduced
or transmitted without the written permission of Selangor Dredging BerhadWHISTLEBLOWING POLICY

Revision 01
Effective Date
27 May 2020

Whistleblowing Policy

Document Ref. No
HR/WB/SOP10/RV01(2020)
LD-GM1.93-RiskMgt-WB(Final)(27 05 2020)[The rest of this page is intentionally left blank]

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WHISTLEBLOWING POLICY1.0OBJECTIVESelangor Dredging Berhad (“SDB” or “Company”) is committed to the highest standard of integrity,
openness and accountability in the conduct of its businesses and operations. This policy outlines therequirements and processes involved in the reporting of misconduct or wrongdoings concerning SDB
that contravene our Brand Promise, Core Values or Code of Business Conduct and Ethics and thehandling of such reports. This policy is applicable to SDB and its subsidiaries and where applicable,references to SDB shall be taken and read to include its subsidiaries.

2.0

POLICYThe objective of this policy is to provide a safe avenue for SDB’s employees and members of thepublic to report or disclose any improper conduct or wrongdoing concerning SDB and to provide
protection for employees and members of the public who report such allegations. Protection ofconfidentiality of whistleblower will be accorded to employees and members of the public, withemployees being given the additional protection that he / she will not be subject to detrimental action
or retaliatory actions at the workplace.
IMPORTANT NOTE: Whilst SDB welcomes disclosures about possible irregularities concerning
SDB, whistleblowers are cautioned against disclosing confidential information previously disclosed
to the following authorities to SDB:
(a)
(b)
(c)
(d)
(e)
(f)
(g)

The Malaysian Anti-Corruption Commission;
The Royal Malaysian Police;
The Royal Malaysian Customs Department;
The Immigration Department;
The Road Transport Department;
The Securities Commission; and/or
The Companies Commission of Malaysia (collectively, the “Authorities”).

Disclosing confidential information already disclosed to the Authorities to any third parties, including
SDB amounts to an offence under Section 8 of the Whistleblower Protection Act (“WPA 2010”),which if convicted, the whistleblower is expose to a penalty of up to RM50,000, a jail term of up to
10 years, or both. Such disclosure would further result in the whistleblower losing the protection ofconfidentiality, protection from detrimental action, and protection from civil, criminal and disciplinary
actions afforded by the Authorities.
To ensure all stakeholders’ interest are protected, SDB will request for a declaration from
whistleblowers that information disclosed to SDB is not confidential information already disclosed
to the Authorities, in order for SDB to comply with Section 8 of the WPA 2010. This declaration isset out in the Whistleblowing Report Form set out in Appendix 1 below.

3.0

SCOPE
This policy is applicable to all stakeholders and employees (which, for the avoidance of doubt, shall
include permanent, contract, temporary employees and interns).

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WHISTLEBLOWING POLICYThis policy applies to the witnessing or discovery or suspicion of misconducts or wrongdoings
concerning SDB such as:a.
b.
c.
d.
e.
f.
g.

Fraud;
Bribery;
Abuse of Power;
Conflict of Interest;
Theft or embezzlement;
Misuse of Company’s Property;
Non-Compliance with Company Policies

The above list is not exhaustive and may be added or changed as required from time to time.
This Policy applies also to any acts, omissions, irregularity, or suspected act of irregularity involving
employees, members of management whether individually, within the Company or with external
parties, which if proven, will constitute an act of misconduct towards the Company or criminal
offence under relevant legislations in force.

4.0

5.0

DEFINITIONSHOD: Head of Department

HR: Human Resources

GGM: Group General Manager

MD: Managing Director

WBC: Whistleblowing Committee

POLICY DETAILS
5.1

Ownership and Responsibility
5.1.1

Employees are to comply with the relevant policies, procedures and ethical work
practices.

5.1.2

An employee discovering or suspecting the occurrence of misconduct orwrongdoings such as those stated in 3.0 is responsible to report such acts to therespective HOD, HR or GGM with evidence to support the incident.
Alternatively, employees can lodge a report of the incident by emailing towhistleblowing@sdb.com.my a completed Whistleblowing Report Form as per
Appendix 1 or return the completed form by hand or by post addressed to the WBC
at 18th Floor, West Block, Wisma Golden Eagle Realty, 142-C, Jalan Ampang, 50450
Kuala Lumpur, Malaysia. The Whistleblowing Report Form can be downloaded fromthe Company’s website www.sdb.com.my.

5.1.3

Third parties, i.e. vendors, contractors, consultants or customers, working for / with
the Company and the general public can also lodge a report of known or suspected
misconduct or wrongdoings such as those stated in 3.0 by emailing towhistleblowing@sdb.com.my a completed Whistleblowing Report Form as per
Appendix 1 or return the completed form by hand or by post addressed to the WBC
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WHISTLEBLOWING POLICY

at 18th Floor, West Block, Wisma Golden Eagle Realty, 142-C, Jalan Ampang, 50450
Kuala Lumpur, Malaysia. The Whistleblowing Report Form can be downloaded fromthe Company’s website www.sdb.com.my.
5.1.4

5.2

5.3

WBC is responsible for conducting investigation to validate the claim and wherenecessary, the execution of Domestic Inquiry.

Ensuring Anonymity and Information Security
5.2.1

The whistleblower may identify himself / herself or remain anonymous whenreporting suspected or known misconduct and wrongdoings.

5.2.2

The identity of the whistleblower shall be kept confidential unless required to bedisclosed by law for instance, if the whistleblower is subsequently required to comeforward as a witness in accordance with any applicable laws and regulations.

5.2.3

No employee who in good faith reports any incidents / instances of misconduct shallsuffer harassment, retaliation or adverse employment consequence.

5.2.4

An employee who retaliates against someone who has reported any incidents /instances of misconduct in good faith is subject to disciplinary action including
termination of employment.

5.2.5

The identity of the accused will also be held confidential except to those involved in
the investigation, GGM and MD.

5.2.6

Information related to the case will be kept within the parties required to conduct theinvestigation and Domestic Inquiry until a verdict is obtained. Thereafter, the casemay be shared with other employees as required by the GGM and MD.

5.2.7

Persons within SDB who are identified in the whistleblowing report will not beallowed to participate or be in any manner involved in the process of handling,
investigating and reporting of the alleged misconduct or wrongdoing.

Reporting Requirements
5.3.1

The whistleblower needs to provide the following information:a. The case details (who, what, when, where, how);b. The actual act observed;c.

The reason or basis for acts of suspicion; andd. Any available form of evidence or other witnesses to support the reportedincident.
Any anonymous report will be considered at the discretion of the Company basedon the nature of the report including supporting credible evidence.
5.3.2

SDB may, as it deems appropriate, direct the whistleblower to report the casedirectly to the appropriate authority if the whistleblower is in possession of prima
facie evidence of misconduct by any employee or member of management which isbelieved to constitute corruption, partaking in any corruption activities or any
equivalent offence.
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5.4

5.5

5.6

6.0

Investigation and Domestic Inquiry
5.4.1

All whistleblowing reports received shall be acknowledged within 24 hours uponreceipt of all required information and the WBC will assess the report prior todetermining the next course of action to be taken based on, inter alia, the severityof the claim and the credibility of information received.

5.4.2

Once the case has been determined as having merit on the face of it, the WBC willconduct investigation with the parties related to the case to establish the validity ofthe claim.

5.4.3

Upon confirmation and collection of sufficient evidence, the WBC may take one ormore of the following actions as it deems appropriate:a.

inform GGM and MD;b.

inform the Audit Committee of the outcome of the investigation if the WBC
considers the severity of the matter warrants a report to the Audit Committee;c.

inform the whistleblower on the findings;

d.

conduct a Domestic Inquiry against the employee involved;e.

make a police report if the misconduct or wrongdoing constitutes a criminaloffence; and / orf.

recommend preventive measures to be taken.

Disciplinary Actions
5.5.1

Where the misconduct or wrongdoing concerns an employee, the type of disciplinary
action that would be imposed against the employee would depend on the severityof the case and will be in line with the punitive actions described in the Industrial
Relations SOP.

5.5.2

In cases where applicable, SDB reserves the right to report the case and submit thesupporting documents to the appropriate authority for further action in addition to
any disciplinary action which may be imposed.

False Accusation
5.6.1We assume all whistleblowing report is done with honorable intentions to protect
SDB and will be treated as such until proven otherwise.

5.6.2

Any employee found deliberately reporting false accusation due to malice,
vengeance or based on hearsay will be subjected to the relevant disciplinary
investigation, inquiry and actions (as per Industrial Relations SOP).

5.6.3

For the avoidance of doubt, SDB reserves the right not to act upon any
whistleblowing report received which it deems to be frivolous or malicious or false.

FURTHER CLARIFICATION
6.1 Employees and stakeholders who require clarification on this policy may email his/her queries towhistleblowing@sdb.com.my.
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WHISTLEBLOWING POLICY

7.0

POLICY UPDATE
7.1 SDB may amend this policy from time to time, as and when necessary, to ensure that this policy
best reflects the highest standard of integrity, openness and accountability in the conduct of its
businesses and operations.

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WHISTLEBLOWING POLICY

Process Flow

Whistleblower discovers
wrongdoing

Whistleblower makes reportNoCase has
merit?

Yes

WBC investigates andobtain supporting evidence

Close caseNo

CaseValid?
Yes

WBC report to GGM andMD and takes action as it
deems appropriate

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WHISTLEBLOWING POLICYAPPENDIX 1
WHISTLEBLOWING REPORT FORM
Please provide the following details for any suspected serious misconduct or any breach or suspected breachof law or regulation that may adversely impact SDB and submit the information directly towhistleblowing@sdb.com.my or return the completed form by hand or by post to Selangor Dredging Berhad,
Whistleblowing Committee at 18th Floor, West Block, Wisma Golden Eagle Realty, 142-C, Jalan Ampang,
50450 Kuala Lumpur, Malaysia.
All information disclosed in this whistleblowing report will be kept strictly confidential.
We may need to obtain further information or call upon your assistance during the investigation stage. As
such, to the extent practicable, please provide your contact details.
WHISTLEBLOWER’S CONTACT INFORMATION(This section may be left blank if whistleblower wants to remain anonymous)
NAME / ID NO. / BADGE NO.
DESIGNATIONDEPARTMENT / OPERATIONCONTACT NUMBERS
E-MAIL ADDRESSSUSPECT(S)’ INFORMATION (must be provided)
NAME / ID NO. / BADGE NO.
DESIGNATIONDEPARTMENT / OPERATIONCONTACT NUMBERS
E-MAIL ADDRESSWITNESS(ES) INFORMATION (if any, to be provided)
NAME
DESIGNATIONDEPARTMENTCONTACT NUMBERS
E-MAIL ADDRESSALLEGATION NO.
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WHISTLEBLOWING POLICYCOMPLAINT: Briefly describe the misconduct / improper activity and how you came to know
about it. Specify what, who, when, where and how. If there is more than one allegation, numbereach allegation and use as many pages as necessary.
Note: * - You SHOULD NOT attempt to obtain evidence for which you do not have a right toaccess since whistleblowers are “reporting parties” and NOT “investigators”.
1. What is the nature of the misconduct / improper activity?

2. Who committed the misconduct / improper activity?

3. When did it happen and when did you notice it?

4. Where did it happen?

5. Is there any evidence that you could provide to us?*

6. Are there any other details or information which could assist us in the investigation?

7. Do you have any others details or information which would assist us in theinvestigation?

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WHISTLEBLOWING POLICYI hereby confirm by disclosing the information set out in this Whistleblowing Report to SDB, I
am not in breach of Section 8 of the Whistleblower Protection Act 2010 (“WPA 2010”).
Yes

[ ]

No[]

Please confirm your declaration by ticking the yes box. If you do not wish to provide a
confirmation, SDB will need to take additional steps to verify the information disclosed is not inbreach of Section 8 of the WPA 2010, including but not limited to reaching out to you to solicit
further information. This will in turn result in delays to the investigation of the matter reported.
Please also be informed that the SDB may not proceed with the investigation of your report if
SDB cannot be reasonably certain that the information you have provided is not in breach ofSection 8 of the WPA 2010.
Date:

Signature / E-signature:

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